- Site: Sellafield
- IR number: 21-008 (SAF)
- Date: June 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Safeguards inspection and assessment plan 2021/22 for Sellafield, ONR Safeguards carries out a number of safeguards compliance inspections at the Sellafield site. One such intervention was performed to inspect SL’s compliance within the Retrievals Value Stream with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy. For this intervention the Magnox Encapsulation Plant (MEP) was selected and the inspection planned as an accountancy focused compliance inspection.
This inspection sought evidence of arrangements and their implementation to make judgements of compliance against the following regulations in NSR19:
- Regulation 6 – Accountancy and control of qualifying nuclear material
- Regulation 9 – Operation of Accountancy and Control Plan
- Regulation 10 – Operating Records
- Regulation 11 – Accounting Records
- Regulation 12 – Accounting Reports
- Regulation 29 – Stock list and accounting records for conditioned and retained waste
- Regulation 30 – Transfers of conditioned waste
Interventions Carried Out by ONR
I carried out an accountancy focused compliance inspection focussed on MEP at the Sellafield nuclear licensed site. The inspection comprised of discussions with SL staff, reviews of operating and accounting records, and a plant walkdown.
The inspection targeted the completeness and correctness of the operating and accounting records (source documentation) which underpinned a sample of batches I selected of Qualifying Nuclear Material (QNM) declared in the accountancy reports for this facility. The inspection also targeted whether these source documents were traceable to the accountancy reports and whether arrangements for generation of source documentation and accountancy reports at MEP were adequately implemented.
This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection guides, which can be found on ONR’s website.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No significant or minor shortfalls in compliance against NSR19 were identified during this intervention.
Based on the sample I inspected, I judge SL has implemented adequate operating and accounting records under Regulations 10 and 11 of NSR19, which are traceable to and underpin the declarations within the accountancy reports submitted to ONR under Regulation 12 of NSR19.
Based on the plant walkdown and discussions I held with the key SL staff on plant and within the Nuclear Material Accountancy and Safeguards team I judge that SL are implementing their arrangements as described in their Accountancy and Control Plan (ACP) as required by Regulation 9 and that implementation of these arrangements is providing appropriate accountancy and control of qualifying nuclear material within this MBA as required in Regulation 6.
I reviewed documentation regarding retained waste records at MEP (QS14.2) and inspected a sample of these. I noted a single transcription error relating to Thorium quantities in an advice note from Harwell. This information did not strictly relate to the retained waste but was provided as part of the pack of documentation. As such, I provided SL with regulatory advice that they should ensure all data, provided to ONR pertaining to a specific batch is correct and complete. The retained waste records I sampled were adequate and therefore I judged SL to be compliant against NSR19, Regulation 29.
NSR19, Regulation 30, pertains to conditioned waste, which I confirmed is not present at QS14.2, therefore I made no regulatory judgement against this regulation.
I noted that in MEP the Plant Information Computer System (PICS) is a core system for accountancy and control of QNM, with ongoing future requirements for continued use. SL acknowledged their system is antiquated, and for that reason, I have regulatory concerns about reliability and resilience . I therefore provided SL with Regulatory Advice to consider the reliability and resilience of these systems, identifying ONMACS FSE 5 as a source for good practice for resilience of NMAC systems.
During this intervention I made 2 conventional safety related observations, neither of which I felt were significant or required immediate action. I also provided 2 good practice observations relating to additional visual verification of drum ID’s and succession planning/knowledge capture for the Nuclear Material Custodian.
1.4 Conclusion of Intervention
Based on the sample inspected during the intervention, I judge that SL are implementing their arrangements for accountancy and control of QNM in-line with regulatory expectations and are compliant with NSR19 Regulations 6, 9, 10, 11, 12 and 29. I did not identify any significant or minor shortfalls.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.